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Sources and Effects
11.1
HAZARDOUS WASTE DEFINED
Purpose and Scope
Definition of Solid Waste
Definition of Hazardous Waste
Exclusions
Small Quantity Generators
Recyclable Materials
Container Residue
11.2
HAZARDOUS WASTE SOURCES
HazardousWastefromSpecific
Sources
Wood Preservation
Inorganic Pigments
Organic Chemicals
Inorganic Chemicals
Pesticides
Explosives
Petroleum Refining
Iron and Steel
Secondary Lead
Veterinary Pharmaceuticals
Ink Formulation
Coking
Hazardous Wastes from Nonspecific
Sources
11.3
EFFECTS OF HAZARDOUS WASTE
Human Health Hazards


Site Safety
Environmental Contamination
Characterization, Sampling,
and Analysis
11.4
HAZARDOUS WASTE CHARACTER-
IZATION
Criteria
Characteristics
Characteristic of Ignitability
Characteristic of Corrosivity
Characteristic of Reactivity
Characteristic of Toxicity
Specific Compounds
11.5
SAMPLING AND ANALYSIS
Sampling Equipment and Procedures
Safety
Sampling Equipment
Procedures
Sample Preservation
Quality Assurance and Quality
Control
Sample Custody
Precision and Accuracy
Analysis
11.6
COMPATIBILITY
11
Hazardous Waste

Paul A. BouisԽMary A. EvansԽLloyd H. Ketchum, Jr.ԽDavid H.F.
LiuԽWilliam C. Zegel
©1999 CRC Press LLC
Risk Assessment and Waste
Management
11.7
THE HAZARD RANKING SYSTEM AND THE
NATIONAL PRIORITY LIST
11.8
RISK ASSESSMENT
Review of Basic Chemical Properties
RA Paradigms
Hazard Identification
Dose-Response Relationship
Exposure Analysis
Risk Characterization
Public Perception of Risk
Risk Management
Pure-Risk Standards
Technology-Based Standards
No Unreasonable Risk
11.9
WASTE MINIMIZATION AND REDUC-
TION
Source Reduction and Control
Input Materials
Technology Changes
Procedural Changes
Product Changes
Waste Exchange

Recycling and Reuse
Direct On-Site Reuse
Additional On-Site Recovery
Off-Site Recovery
Sale for Reuse Off-Site
11.10
HAZARDOUS WASTE TRANSPORTATION
Generator Requirements
EPA ID Number
Pretransport Regulations
Waste Accumulation
The Manifest
Recordkeeping and Reporting
Export and Import of Hazardous
Waste
Transporters and Carriers
Hazardous Materials Transportation Act
and Other Regulations
Modes of Transport
Treatment and Disposal
11.11
TREATMENT, STORAGE, AND DISPOSAL
REQUIREMENTS
General Facility Standards
Preparedness and Prevention
Contingency Plan and Emergency
Procedure
General Technical Standards for Interim
Status Facilities
Groundwater Monitoring

Closure
Financial Requirements
11.12
STORAGE
Containers
Tanks
Surface Impoundments
Waste Piles
Landfills
Underground Injection
11.13
TREATMENT AND DISPOSAL ALTER-
NATIVES 1302
Available Processes
Process Selection
11.14
WASTE DESTRUCTION TECHNOLOGY
Incineration
Incinerator System Design
Liquid Injection Incinerators
Rotary Kiln Incinerators
Fixed Hearth Incinerators
Fluidized Bed Incinerators
Process Performance
Wet Air Oxidation
Process Description
Process Characteristics
Applicability/Limitations
Supercritical Water Oxidation
Process Description

Applicability/Limitations
11.15
WASTE CONCENTRATION TECHNOLOGY
Gravity Separation
Sedimentation
©1999 CRC Press LLC
©1999 CRC Press LLC
Centrifugation
Flocculation
Oil/Water Separation
Dissolved Air Flotation
Heavy Media Separation
Phase Change
Evaporation
Air Stripping
Steam Stripping
Distillation
Dissolution
Soil Flushing/Soil Washing
Chelation
Liquid/Liquid Extraction
Supercritical Extraction
Size/Adsorptivity/Ionic Characteristics
Filtration
Carbon Adsorption
Reverse Osmosis
Ion Exchange
Electrodialysis
Chemical Treatment Processes
Neutralization

Chemical Precipitation
Oxidation and Reduction
Hydrolysis
Chemical Oxidation
Electrolytic Oxidation
Alkaline Metal Dechlorination
Alkaline Metal/Polyethylene Glycol
(APEG)
Based-Catalyzed Decomposition
11.16
SOLIDIFICATION AND STABILIZATION
TECHNOLOGIES
Applications
Technology Description
Cement-based Processes
Pozzolanic Processes
Thermoplastic Processes
Organic Polymer Processes
Technology Limitations
Performance Testing
11.17
BIOLOGICAL TREATMENT
Aerobic Biological Treatment
Description
Applicability/Limitations
Activated Sludge
Description
Applicability/Limitations
Rotating Biological Contractors
Description

Applicability/Limitations
Bioreclamation
Description
Applicability/Limitations
Anaerobic Digestion
Description
Applicability/Limitations
White Rot Fungus
Description
Applicability/Limitations
11.18
BIOTREATMENT BY SEQUENCING BATCH
REACTORS
Process Description
Modes of Operation
Idle
Static, Mixed, and Aerated Fill
React
Settle
Draw
Laboratory Treatability Studies
Storage and Leak
Detection
11.19
UNDERGROUND STORAGE TANKS
Problems and Causes
Galvanic Corrosion
Faulty Installation
Piping Failures
Spills and Overfills

Compatibility of UST and
Contents
UST Regulations
Design, Construction, and
Installation
Spills and Overfills Control
Repairs
Leak Detection
Out of Service Systems and
Closure
Financial Responsibility
11.20
LEAK DETECTION AND REMEDIATION
Tank Monitoring
Volumetric Leak Testing
Nonvolumetric Leak Testing
Inventory Monitoring
Environmental Monitoring
Corrective Technologies
Radioactive Waste
11.21
PRINCIPLES OF RADIOACTIVITY
Types of Radioactivity
Alpha Particles
Beta Particles
Gamma Rays
Half-Life and Decay of Radioisotopes
11.22
SOURCES OF RADIOACTIVITY IN THE
ENVIRONMENT

Nuclear Fuel Cycle
Mining Activities
Medical and Laboratory Facilities
Nuclear Weapons Testing
Natural Deposits
11.23
SAFETY STANDARDS
Protection from Exposure
Basic Radiation Safety
External Radiation
Internal Radiation
11.24
DETECTION AND ANALYSIS
Radiation Monitoring
Survey Instruments
Device Calibration
Radioactivity Analysis
Analytical Counting Instruments
Analytical Methods
11.25
MINING AND RECOVERY OF RADIOACTIVE
MATERIALS
11.26
LOW-LEVEL RADIOACTIVE WASTE
Waste Classification
Sources of Low-Level Radioactive
Waste
Nuclear Fuel Cycle Waste
Industrial Waste
Government Waste

Medical Waste
Academic Waste
Greater Than Class C Waste
Below Regulatory Concern Waste
Mixed Waste
Quantities of LLRW Generated
LLRW Commercial Disposal Sites
LLRW Reduction Processes
Waste Minimization
Segregation
Decay
Sewage Disposal
Deregulation
Dewatering
Compaction
Incineration
Liquid and Gaseous Effluent
Treatment
Liquid Effluents
Gaseous Effluents
Conditioning Techniques
Cementation
Bituminization
Polymerization
Vitrification
Disposal Techniques
Shallow Land Burial
Disposal Vaults
Earth-Mounded Concrete Bunkers
11.27

HIGH-LEVEL RADIOACTIVE WASTE
11.28
TRANSPORT OF RADIOACTIVE
MATERIALS
Materials Subject to DOT Regula-
tions
Regulations for Safe Transport
Quantity Limits and Packaging
External Radiation and Contamination
Levels
©1999 CRC Press LLC
Purpose and Scope
Hazardous waste is often defined as waste material that
everyone wants picked up but no one wants put down.
The legal and scientific definitions have become more com-
plex as more compounds are found and more is learned
about the toxicity of compounds and elements. The
Resource Conservation and Recovery Act (RCRA) haz-
ardous waste regulations (40 CFR §261 1987) provide the
legal definition of hazardous waste. This definition is not
always clear because the regulations are written in lan-
guage general enough to apply to all possible situations,
including unusual terminology, several exemptions, and
exclusions.
The purpose of this section is to present the various de-
finitions of hazardous waste in a manner useful to the en-
vironmental engineer. To be a hazardous waste, material
must first conform to the definition of waste; second, it
must fit the definition of solid waste; and third, it must fit
the definition of hazardous waste.The environmental en-

gineer must test the material against each of these defini-
tions. This section assumes that the generator can demon-
strate whether the material is indeed a waste.
Definition of Solid Waste
Solid waste need not literally be a solid. It may be a solid,
a semisolid, a liquid, or a contained gaseous material. In
accordance with RCRA regulations, a solid waste is any
discarded material that is not specifically excluded by the
regulation or excluded by granting of a special variance
by the regulatory agency. Discarded material is considered
abandoned, recycled, or inherently wastelike. Materials are
considered abandoned if they are disposed of, burned or
incinerated, or accumulated, stored, or treated (but not re-
cycled) before being abandoned.
Materials are considered recycled if they are recycled or
accumulated, stored, or treated before recycling. However,
materials are considered solid waste if they are used in a
manner constituting disposal, burned for energy recovery,
reclaimed, or accumulated speculatively. Table 11.1.1 pre-
sents various classes of materials and general situations in
which they would be considered solid wastes.
Inherently wastelike materials are solid wastes when
they are recycled in any manner. This includes:

Certain wastes associated with the manufacturing
of tri-, tetra-, or pentachlorophenols or tetra-,
penta-, or hexachlorobenzenes (for listed wastes
F020, F021, F022, F023, F026, and F028, see the
following section for an explanation of F desig-
nations


Secondary materials that, when fed to a halogen
acid furnace, exhibit characteristics of hazardous
waste or are listed as hazardous waste (see section
2.2)

Other wastes that are ordinarily disposed of,
burned, or incinerated

Materials posing a substantial hazard to human
health and the environment when they are recy-
cled.
For a material to be considered recycled and not a solid
waste, the material must be used or reused in making a
product without reclamation. The material is also consid-
ered recycled if it is used as an effective substitute for com-
mercial products or returned to the process from which it
was generated without reclamation. In this latter case, the
material must be a substitute for raw material feedstock,
and the process must use raw materials as its principal
feedstocks.
The process for determining whether a waste is a solid
waste is summarized in Figure 11.1.1.
Definition of Hazardous Waste
A solid waste is classified as a hazardous waste and is sub-
ject to regulation if it meets any of the following four con-
ditions:
The waste is a characteristic hazardous waste, exhibiting
any of the four characteristics of a hazardous waste: ig-
nitability, corrosivity, reactivity, or toxicity (see Section

11.4 Hazardous Waste Characterization).
The waste is specifically listed as hazardous in one of the
four tables in Part 261, Subpart D of the RCRA regu-
lations: Hazardous Wastes From Nonspecific Sources,
©1999 CRC Press LLC
Sources and Effects
11.1
HAZARDOUS WASTE DEFINED
Hazardous Wastes From Specific Sources, Acute
Hazardous Wastes, or Toxic Wastes.
The waste is a mixture of a listed hazardous waste and a
nonhazardous waste.
The waste is declared hazardous by the generator of the
waste. This is true even if the waste is not hazardous
by any other definition and was declared hazardous in
error.
The environmental engineer is referred to Section 261.3 of
the RCRA regulations (40 CFR §261.3) for more infor-
mation on exceptions to these criteria. A hazardous waste
must be a solid waste and thus may be in the form of a
solid, semisolid, liquid, or contained gas.
The EPA developed listed wastes by examining differ-
ent types of wastes and chemical products to see if they
exhibited one of the characteristics of a hazardous waste,
then determining whether these met the statutory defini-
tion of hazardous waste, were acutely toxic or acutely haz-
ardous, or were otherwise toxic. The following series let-
ters denote the origins of such wastes.
F Series includes hazardous wastes from nonspecific
sources (e.g., halogenated solvents, nonhalogenated

solvents), electroplating sludges, cyanide solutions
from plating batches). These are generic wastes com-
©1999 CRC Press LLC
TABLE 11.1.1 CONDITIONS UNDER WHICH COMMON MATERIALS ARE SOLID WASTES
Use Constituting Energy Speculative
Material Disposal* Recovery Fuel† Reclamation‡ Accumulation§
Spent Materials Solid Waste Solid Waste Solid Waste Solid Waste
Sludge Solid Waste Solid Waste Solid Waste Solid Waste
Sludge Solid Waste Solid Waste NOT a Solid Waste Solid Waste
Exhibiting
Characteristics of
Hazardous Waste
By-products Solid Waste Solid Waste Solid Waste Solid Waste
By-products Solid Waste Solid Waste NOT a Solid Waste Solid Waste
Exhibiting
Characteristics of
Hazardous Waste
Commercial Solid Waste Solid Waste NOT a Solid Waste NOT a Solid Waste
Chemical
Products
Scrap Metal Solid Waste Solid Waste Solid Waste Solid Waste
*Use constituting disposal includes application to or placement on the land, and use in the production of (or incorporation in) products that are applied to or
placed on the land. Exceptions are made for materials that are applied to the land in ordinary use.
†Energy recovery fuel includes direct burning, use in producing a fuel, and incorporation in a fuel. However, selected commercial chemical products are not solid
wastes if their common use is fuel.
‡Reclamation includes materials processed to recover useable products, or regenerated. Examples are recovery of lead from old automobile batteries or used wheel
weights and regeneration of spent catalysts or spent solvents.
§Speculative accumulation refers to materials accumulated before the precise mechanism for recycle is known. This designation can be avoided if: the material is po-
tentially recyclable; a feasible means for recycle is available; and during each calendar year the amount of material recycled or transferred to another site for recycling
equals at least 75% of the material accumulated at the beginning of the period.

All Materials
YES
NO
Does §261.4(a) exclude your material
from regulation under RCRA because
it is one of the following:
1. Domestic sewage
2. CWA point source discharge
3. Irrigation return flow
4. AEC source, special nuclear or
by-product material
5. In situ mining waste
THE MATERIAL
IS NOT A RCRA
SOLID WASTE
THE MATERIAL IS A RCRA SOLID WASTE
whether it is:
1. Discarded
2. Used
3. Reused
4. Recycled
5. Reclaimed
6. Stored or accumulated for purposes
1-5 above
Solid, liquid, semi-solid or contained
gaseous material that is:
1. Discarded
2. Used for its intended purpose
3. A manufacturing or mining
by-product

Garbage, refuse
or sludge
Other
FIG. 11.1.1 Definition of a solid waste.
monly produced by manufacturing and industrial
processes.
K Seriesis composed of hazardous waste from specific
sources (e.g., brine purification muds from the mercury
cell process in chlorine production where separated, pu-
rified brine is not used and API separator sludges). These
are wastes from specifically identified industries, such
as wood preserving, petroleum refining and organic
chemical manufacturing.
P Seriesdenotes acutely hazardous waste of specific com-
mercial chemical products (e.g., potassium silver
cyanide, toxaphene, or arsenic oxide) including dis-
carded and off-specification products, containers, and
spill residuals.
U Seriesincludes toxic hazardous wastes that are chemi-
cal products, (e.g., xylene, DDT, and carbon tetrachlo-
ride) including discarded products, off-specification
products, containers, and spill residuals.
Acute hazardous wastes are defined as fatal to humans in
low doses, or capable of causing or contributing to seri-
ous irreversible, or incapacitating reversible illness. They
are subject to more rigorous controls than other listed haz-
ardous wastes.
Toxic hazardous wastes are defined as containing chem-
icals posing substantial hazards to human health or the
environment when improperly treated, stored, transported,

or disposed of. Scientific studies show that they have toxic,
carcinogenic, mutagenic, or teratogenic effects on humans
or other life forms.
The environmental engineer needs to understand when
a waste becomes a hazardous waste, since this change
initiates the regulatory process. A solid waste that is not
excluded from regulation (see previous sections) becomes
a hazardous waste when any of the following events occur:

For listed wastes—when the waste first meets the
listing description

For mixtures of solid waste and one or more listed
wastes—when a listed waste is first added to the
mixture

For other wastes—when the waste first exhibits
any of the four characteristics of a hazardous
waste
After a waste is labeled hazardous, it generally remains a
hazardous waste forever. Some characteristic hazardous
wastes may be declared no longer hazardous if they cease
to exhibit any characteristics of a hazardous waste.
However, wastes that exhibit a characteristic at the point
of generation may still be considered hazardous even if
they no longer exhibit the characteristic at the point of
land disposal.
Figures 11.1.2 and 11.1.3 summarize the process used
to determine whether a solid waste is a hazardous waste
and whether it is subject to special provisions for certain

hazardous wastes.
EXCLUSIONS
The regulations allow several exemptions and exclusions
when determining whether a waste is hazardous. These ex-
clusions center on recycled wastes and several large-vol-
©1999 CRC Press LLC
YES
NO
Is the solid waste
excluded from regulation
under §261.4(b)?
Is the solid waste listed in
Part 261, Subpart D, or is it
a mixture that contains a waste
listed in Subpart D?
Has the waste or mixture
been excluded from the lists in
Subpart D or §261.3 in accordance
with §§260.20 and 260.22?
Does the waste exhibit
any of the characteristics
specified in Part 261,
Subpart C?
THE WASTE IS
SUBJECT TO CONTROL
UNDER SUBTITLE D
(if land disposed)
THE WASTE IS
A HAZARDOUS WASTE
(see Figure 12.1)

YES
NO
YES
NO
NO
YES
YES
YES
Is it generated by a
small quantity generator
as defined in §261.5?
Is it intended
to be legitimately and
beneficially used, re-used,
recycled, or reclaimed?
Is it a sludge or is it
listed in Part 261, Subpart D
or is it a mixture containing
a waste listed in Part 261,
Subpart D?
IT IS SUBJECT TO THE FOLLOWING
REQUIREMENTS WITH RESPECT TO
ITS TRANSPORTATION OR STORAGE:
—Notification under Section 3010
—Parts 262 and 263
—Parts 264, Subparts A through E
—Part 265, Subparts A through E, and
G,H,I,J,& L
—Parts 270 and 124
It is subject to the

special requirements of §261.5
Therefore, it must be
intended to be discarded.
IT IS SUBJECT TO THE
SUBTITLE C REGULATIONS

IT IS NOT SUBJECT TO
REGULATION UNDER
SUBTITLE C
THE WASTE IS A
HAZARDOUS WASTE
(see Figure 12.2)
NO
YES
YES
NO
NO
FIG. 11.1.2Definition of a hazardous waste.
FIG. 11.1.3Special provisions for certain hazardous waste.
ume or special-interest wastes. Wastes specifically excluded
from regulation include industrial wastewater discharges,
nuclear materials, fly ash, mining overburden, drilling flu-
ids, and ore processing wastes. A major exemption is also
granted to small-quantity generators of hazardous wastes
(i.e., those generating less than 100 kg/month [220
lb/month] of hazardous wastes).
The exclusions cover materials that are not solid wastes,
solid wastes that are not hazardous wastes, hazardous
wastes that are exempt from certain regulations, and sam-
ples associated with chemical and physical testing or treata-

bility studies. For regulatory purposes, the following are
not considered solid wastes:
Domestic sewage, or any mixture of domestic sewage and
other wastes, passing through a sewer system to a pub-
licly-owned treatment works
Industrial wastewater point discharges regulated under
Section 402 of the Clean Water Act
Irrigation return flows
Source, special nuclear, or by-product material as defined
by the Atomic Energy Act of 1954, as amended
Materials subject to in situ mining techniques but not re-
moved from the ground as part of the extraction process
Pulping liquids that are reclaimed in a pulping liquor re-
covery furnace and reused in the pulping process
Spent sulfuric acid used to produce virgin sulfuric acid
Secondary materials that are reclaimed and, with certain
restrictions, returned to their original generation
process(es) and reused in the production process
Spent wood-preserving solutions that are reclaimed and
reused for their original intended purpose
Wastewaters from the wood-preserving process that are
reclaimed and reused to treat wood
Listed hazardous wastes from coking and coke by-prod-
ucts processes that are hazardous only because they ex-
hibit toxicity characteristics when, after generation, they
are (1) recycled to coke ovens, (2) recycled to the tar re-
covery process as a feedstock to produce coal tar, or (3)
mixed with coal tar prior to the tar’s sale or refining
Nonwastewater splash condenser dross residue resulting
from treating emission control dust and sludge in high-

temperature metals-recovery units in primary steel pro-
duction (a listed waste)
The following solid wastes are not considered hazardous
by the RCRA regulations:
Household wastes, including garbage, trash, and sanitary
wastes in septic tanks
Solid wastes generated in growing and harvesting agricul-
tural crops or raising animals; this includes animal ma-
nures that are returned to the soil as fertilizers
Mining overburden returned to the mine site
Fly ash waste, bottom ash waste, slag waste, and flue gas
emission control waste, generated from coal or other
fossil fuels combustion
Drilling fluids, produced waters, and other wastes associ-
ated with the exploration, development, or production
of crude oil, natural gas, or geothermal energy
Waste that could be considered hazardous based on the
presence of chromium if it can be demonstrated that
the chromium is not in the hexavalent state. Such a
demonstration is based on information showing only
trivalent chromium in the processing and handling of
the waste in a non-oxidizing environment, or a specific
list of waste sources known to contain only trivalent
chromium.
Solid waste from extracting, beneficiating, and processing
of ores and minerals
Cement kiln dust waste, unless the kiln is used to burn or
process hazardous waste
Before an environmental engineer concludes a company or
concern is not subject to regulation under RCRA, the en-

gineer should confirm this conclusion via the RCRA
Hotline (1-800-424-9346). Preferably, the decision should
also be confirmed by an attorney or other qualified pro-
fessional familiar with RCRA regulations.
SMALL-QUANTITY GENERATORS (40
CFR §261.5)
A small-quantity generator is conditionally exempt if it
generates no more than 100 kg of hazardous waste in a
calendar month. In determining the quantity of hazardous
waste generated in a month, the generator does not need
to include hazardous waste removed from on-site storage,
only waste generated that month. Also excluded is waste
that is counted more than once. This includes hazardous
waste produced by on-site treatment of already-counted
hazardous waste, and spent materials that are generated,
reclaimed, and subsequently reused on site, so long as such
spent materials have been counted once.
The limits on generated quantities of hazardous waste
are different for acute hazardous waste (P list). The limit
is equal to the total of one kg of acute hazardous waste
or a total of 100 kg of any residue or contaminated soil,
waste, or other debris resulting from the clean-up of any
spilled acute hazardous wastes.
With exceptions, wastes generated by conditionally ex-
empt small-quantity generators are not subject to regula-
tion under several parts of RCRA (Parts 262 through 266,
268, and Parts 270 and 124 of Chapter 2, and the notifi-
cation requirements of section 3010). The primary excep-
tion is compliance with section 262.11, hazardous waste
determination. Hazardous wastes subject to these reduced

requirements may be mixed with nonhazardous wastes and
remain conditionally exempt, even though the mixture ex-
ceeds quantity limits. However, if solid waste is mixed with
a hazardous waste that exceeds the quantity exclusion
level, the mixture is subject to full regulation. If hazardous
wastes are mixed with used oil and this mixture is to be
©1999 CRC Press LLC
burned for energy recovery, the mixture is subject to used
oil management standards (Part 279 of RCRA).
RECYCLABLE MATERIALS (40 CFR
§261.6)
Recycled hazardous wastes are known as recyclable ma-
terials. These materials remain hazardous, and their iden-
tification as recyclable materials does not exempt them
from regulation. With certain exceptions, recyclable ma-
terials are subject to the requirements for generators, trans-
porters, and storage facilities. The exceptions are wastes
regulated by other sections of the regulations and wastes
that are exempt, including: waste recycled in a manner
constituting disposal; waste burned for energy recovery in
boilers and industrial furnaces; waste from which precious
metals are reclaimed; or spent lead-acid batteries being re-
claimed. Wastes generally exempt from regulation are re-
claimed industrial ethyl alcohol, used batteries or cells re-
turned to a battery manufacturer for regeneration, scrap
metal, and materials generated in a petroleum refining fa-
cility. Recycled used oil is subject to used oil management
standards (Part 279 of RCRA).
CONTAINER RESIDUE (40 CFR §261.7)
Any hazardous waste remaining in a container or an in-

ner liner removed from an empty container is not subject
to regulation. The problem is determining whether a con-
tainer is empty or not. RCRA regulations consider a con-
tainer empty when all possible wastes are removed using
common methods for that type of container, and no more
than an inch (2.5 cm) of residue remains on the bottom of
the container or liner. Alternately, a container with a vol-
ume of 110 gal or less can be considered empty if no more
than 3% of the capacity, by weight, remains in the con-
tainer or liner. Larger containers are considered empty
when no more than 0.3% of capacity, by weight, remains
in the container or liner. If the material in the container
was a compressed gas, the container is considered empty
when its pressure is reduced to atmospheric pressure.
Regarding acute hazardous waste (P list), the test for an
empty container is much more stringent. The container or
inner liner must be triple-rinsed using a solvent capable of
removing the commercial chemical product or manufac-
turing chemical intermediate. Alternative cleaning methods
can be used if they are demonstrated to be equivalent to or
better than triple rinsing. Of course, a container can also
be considered empty if a contaminated liner is removed.
—Mary A. Evans
William C. Zegel
References
Code of Federal Regulations. (1 July 1987): Title 40, sec. 261.
U.S. Environmental Protection Agency (EPA). 1986. RCRA orientation
manual.” Office of Solid Waste, Washington, D.C.
©1999 CRC Press LLC
11.2

HAZARDOUS WASTE SOURCES
The reported quantities of hazardous waste generated in
the U.S. remained in the range of 250–270 million metric
tn per year through most of the 1980s. Figure 11.2.1 in-
dicates which industrial sectors generate these wastes. The
majority of hazardous waste is generated by the chemical
manufacturing, petroleum, and coal processing industries.
As Figure 11.2.2 shows, waste generation is not broadly
distributed throughout these industries; instead, a few
dozen facilities account for most waste generation. While
it is striking that a few dozen manufacturing facilities gen-
erate most of the country’s hazardous wastes, these waste
generation rates must be viewed in context. Figure 11.2.3
shows that 250–270 million tn of hazardous waste gener-
ated annually are over 90% wastewater. Thus, the rate of
generation of hazardous constituents in the waste is prob-
Chemical Products
Petroleum/Coal
Electrical/Gas/Sanitary
Primary Metals
Machinery
Other
FIG. 11.2.1. Hazardous waste generation in 1986, classified
by industry sector. (Reprinted from U.S. Environmental
Protection Agency (EPA), 1988, 1986 national survey of haz-
ardous waste treatment, storage, disposal and recycle facilities,
EPA/530-SW-88/035.)
ably on the order of 10 to 100 million tons per year. In
relation to the 300ϩ million tons of commodity chemicals
produced annually and the 1000 million tons of petroleum

refined annually (C&E News 1991), the mass of hazardous
constituents in waste is probably less than 5% of all chem-
ical production.
Examples of basic industries and types of hazardous
wastes produced are listed in Table 11.2.1, illustrating the
©1999 CRC Press LLC
FIG. 11.2.3 Flow of industrial hazardous waste treatment operations (1986 data in tn per yr).
Top 50 Units
Top 40 Units
Top 30 Units
Top 20 Units
Top 10 Units
100
80
60
40
20
0
Percentage of Hazardous Waste Managed
FIG. 11.2.2 Percentages of hazardous waste managed in the
50 largest facilities in 1986. (Reprinted from U.S. EPA, 1988.)
U.S
Industry
(Aggregated)
1.18
1.44
0.96
1.44
1.09
40

488
0.3
0.2
0.3
Air Emissions - 1
Discharge
0.77
0.38
3.17
0.68
28.73
Land Treatment
Solidification
Fuel
Blending
Reuse
As Fuel
Solvent
Recovery
Metals
Recovery
Other
Recovery
Incineration
Landfills
Waste Piles
Wastewater
Treatment
Surface
Impoundments

Underground
Injection
Discharge
wide range and complexity of the wastes. However, these
few examples do not adequately suggest the numbers and
kinds of hazardous chemical constituents in hazardous
wastes to be managed. There are approximately 750 listed
wastes in 40 CFR Part 261, and countless more charac-
teristic wastes. The intensity of industrial competition con-
stantly engenders the introduction of new products, thus
wastes are generated at an awesome pace.
Hazardous Waste from Specific
Sources (40 CFR §261.32)
The following solid wastes are listed as hazardous wastes
from a specific source unless they meet an exclusion. Except
for K044, K045, and K047, which are reactive wastes, they
are toxic wastes.
WOOD PRESERVATION
Bottom sediment sludge from wastewater treatment in
wood-preserving processes using creosote or pentachloro-
phenol (K001) is a hazardous waste.
©1999 CRC Press LLC
TABLE 11.2.1 TYPES OF HAZARDOUS WASTE
Industry Wastes Produced
Chemical Manufacturing • Spent solvents and still bottoms
White spirits, kerosene, benzene, xylene, ethyl benzene, toluene, isopropanol,
toluene diisocyanate, ethanol, acetone, methyl ethyl ketone, tetrahydrofuran,
methylene chloride, 1,1,1-trichloroethane, trichloroethylene
• Ignitable wastes not otherwise specified (NOS)
• Strong acid/alkaline wastes

Ammonium hydroxide, hydrobromic acid, hydrochloric acid, potassium hydroxide,
nitric acid, sulfuric acid, chromic acid, phosphoric acid
• Other reactive wastes
Sodium permanganate, organic peroxides, sodium perchlorate, potassium perchlorate,
potassium permanganate, hypochlorite, potassium sulfide, sodium sulfide
• Emission control dusts and sludges
• Spent catalysts
Construction • Ignitable paint wastes
Ethylene dichloride, benzene, toluene, ethyl benzene, methyl isobutyl ketone,
methyl ethyl ketone, chlorobenzene
• Ignitable wastes not otherwise specified (NOS)
• Spent solvents
Methyl chloride, carbon tetrachloride, trichlorotrifluoroethane, toluene, xylene,
kerosene, mineral spirits, acetone
• Strong acid/alkaline wastes
Ammonium hydroxide, hydrobromic acid, hydrochloric acid, hydrofluoric acid,
nitric acid, phosphoric acid, potassium hydroxide, sodium hydroxide, sulfuric acid
Metal Manufacturing • Spent solvents and solvent still bottoms
Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane,
carbon tetrachloride, toluene, benzene, trichlorofluoroethane, chloroform,
trichlorofluoromethane, acetone, dichlorobenze, xylene, kerosene, white spirits,
butyl alcohol
• Strong acid/alkaline wastes
Ammonium hydroxide, hydrobromic acid, hydrochloric acid, hydrofluoric acid,
nitric acid, phosphoric acid, nitrates, potassium hydroxide, sodium hydroxide,
sulfuric acid, perchloric acid, acetic acid
• Spent plating wastes
• Heavy metal wastewater sludges
• Cyanide wastes
• Ignitable wastes not otherwise specified (NOS)

• Other reactive wastes
Acetyl chloride, chromic acid, sulfides, hypochlorites, organic peroxides, perchlorates,
permanganates
• Used oils
Paper Industry • Halogenated solvents
Carbon tetrachloride, methylene chloride, tetrachloroethylene, trichloroethylene,
1,1,1-trichloroethane, mixed spent halogenated solvents
• Corrosive wastes
Corrosive liquids, corrosive solids, ammonium hydroxide, hydrobromic acid,
hydrochloric acid, hydrofluoric acid, nitric acid, phosphoric acid, potassium hydroxide,
sodium hydroxide, sulfuric acid
• Paint wastes
Combustible liquid, flammable liquid, ethylene dichloride, chlorobenzene,
methyl ethyl ketone, paint waste with heavy metals
• Solvents
Petroleum distillates
Source: Reprinted from U.S. Environmental Protection Agency (EPA), Does your business produce hazardous wastes? (Office of Solid Waste and Emergency
Response, (EPA/530-SW-010, Washington, D.C.)
©1999 CRC Press LLC
INORGANIC PIGMENTS
Hazardous wastes include wastewater treatment sludge
from the production of various metal-based pigments:
chrome yellow and orange (K002), molybdate orange
(K003), zinc yellow (K004), chrome green from the sol-
vent recovery column in the production of toluene di-
iosocyanate via phosgenation of toluenediamine (K005),
anhydrous and hydrated chrome-oxide green (K006), iron
blue (K008), and oven residue from the production of
chrome-oxide green (K008).
ORGANIC CHEMICALS

Numerous hazardous wastes occur in organic chemical pro-
duction facilities. In the production of acetaldehyde from
ethylene, distillation bottoms (K009) and distillation side
cuts (K010) are hazardous wastes. In acrylonitrile produc-
tion, the bottom streams from the wastewater stripper
(K011), the acetonitrile column (K013), and the acetonitrile
purification column (K014) are hazardous wastes. In 1,1,1-
trichlorethane production, hazardous wastes include spent
catalyst from the hydrochlorinator reactor (K028), waste
from the product steam stripper (K029), distillation bottoms
(K095), and heavy ends from the heavy end column (K096).
In the production of toluenediamine via hydrogenation
of dinitrotoluene, hazardous wastes are generated in reac-
tion by-product water from the drying column (K112) and
condensed liquid light ends (K113), vicinals (K114), and
heavy ends (K115) from the purification of toluenediamine.
In the production of ethylene dibromide via bromina-
tion of ethylene, hazardous wastes result from reactor vent
gas scrubber wastewater (K117), spent adsorbent solids
(K118), and still bottoms (K136) from purification.
Hazardous wastes are found in heavy ends or still bot-
toms from benzyl chloride distillation (K015), ethylene
dichloride in ethylene dichloride production (K019), and
vinyl chloride in vinyl chloride monomer production
(K020). Heavy ends or distillation residues from carbon
tetrachloride production (K016); the purification column in
the production of epichlorohydrin (K017); the fractiona-
tion column in ethyl chloride production (K018); the pro-
duction of phenol/acetone from cumene (K022); the pro-
duction of phthalic anhydride from naphthalene (K024);

the production of phthalic anhydride from ortho-xylene
(K094); the production of nitro-benzene by the nitration
of benzene (K025); the combined production of
trichloroethylene and perchloroethylene (K030); the pro-
duction of aniline (K083); and the production of chloroben-
zenes (K085) are also hazardous wastes.
Other sources of hazardous wastes include distillation
light ends from the production of phthalic anhydride from
ortho-xylene (K093) or naphthalene (K024); aqueous
spent antimony catalyst waste from fluoromethanes pro-
duction (K021); stripping still tails from the production of
methyl ethyl pyridines (K026); centrifuge and distillation
residues from toluene diisocyanate production (K027);
process residues from aniline extraction in aniline pro-
duction (K103); combined wastewater streams generated
from nitrobenzene/aniline production (K104); the sepa-
rated aqueous stream from the reactor product washing
step in the production of chlorobenzenes (K105); and the
organic condensate from the solvent recovery column in
the production of toluene diisocyanate via phosgenation
of toluenediamine.
INORGANIC CHEMICALS
Chlorinated hydrocarbon waste from the purification step
of the diaphragm cell process using graphite anodes
(K073); wastewater treatment sludge from the mercury cell
process (K106); and brine purification muds from the mer-
cury cell process where separately prepurified brine is not
used (K071) are hazardous wastes related to the produc-
tion of chlorine.
PESTICIDES

Hazardous wastes are generated in the production of nine
pesticides: MSMA and cacodylic acid, chlordane, creosote,
disulfoton, phorate, toxaphene, 2,4,5–T, 2,4–D, and eth-
ylenebisdithiocarbamic acid and its salts. In MSMA and
cacodylic acid production, hazardous waste is generated
as by-product salts (K031). In chlordane production, haz-
ardous wastes include: wastewater treatment sludge
(K032); wastewater and scrub water from the chlorination
of cyclopentadiene (K033); filter solids from the filtration
of hexachlorocyclopentadiene (K034); and vacuum strip-
per discharge from the chlordane chlorinator (K097).
Wastewater treatment sludges generated in creosote pro-
duction (K035) are also defined as hazardous waste.
Hazardous wastes from the production of disulfoton are
still bottoms from toluene reclamation distillation (K036),
and wastewater treatment sludges (K037). Phorate pro-
duction generates hazardous wastes from washing and
stripping wastewater (K038), wastewater treatment sludge
(K040), and filter cake from filtration of diethylphospho-
rodithioic acid (K039).
Wastewater treatment sludge (K041) and untreated
process wastewater (K098) from toxaphene production
and heavy ends, or distillation residues from tetra-
chlorobenzene in 2,4,5–T production (K042) are haz-
ardous wastes. Similarly, 2,6–dichlorophenol waste
(K043) and untreated wastewater (K099) from 2,4–D pro-
duction are hazardous wastes.
Hazardous wastes from the production of ethylenebis-
dithiocarbamic acid and its salts are: process wastewaters
(including supernates, filtrates, and washwaters) (K123);

reactor vent scrubber water (K124); filtration, evapora-
tion, and centrifugation solids (K125); and baghouse dust
and floor sweepings in milling and packaging operations
(K126).
EXPLOSIVES
Hazardous wastes from explosives production include:
wastewater treatment sludges from manufacturing and
processing explosives (K044) and manufacturing, formu-
lation, and loading lead-based initiating compounds
(K046); pink or red water from TNT operations (K047);
and spent carbon from the treatment of wastewater-con-
taining explosives (K045).
PETROLEUM REFINING
Dissolved air flotation (DAF) float (K048), slop oil emul-
sion solids (K049), heat exchanger bundle cleaning sludge
(K050), API separator sludge (K051), and tank bottoms
from storage of leaded fuel (K052) are hazardous wastes.
IRON AND STEEL
Emission control dust and sludges from primary steel pro-
duction in electric furnaces (K061) and spent pickle liquor
generated in steel finishing operations (K062) are haz-
ardous wastes.
SECONDARY LEAD
Emission control dust and sludge (K069) and waste solu-
tion from acid leaching of emission control dust and sludge
(K100) are hazardous wastes.
VETERINARY PHARMACEUTICALS
Wastewater treatment sludges generated in the production
of veterinary pharmaceuticals from arsenic or organo-ar-
senic compounds (K084), distillation tar residues from the

distillation of aniline-based compounds (K101), and
residue from the use of activated carbon for decoloriza-
tion (K102) are hazardous wastes.
INK FORMULATION
Solvent washes and sludges, caustic washes and sludges,
or water washes and sludges from cleaning tubs and equip-
ment used in ink formulation from pigments, driers, soaps,
and stabilizers containing chromium and lead are haz-
ardous wastes (K086).
COKING
Ammonia still lime sludge (K060) and decanter tank tar
sludge (K087) are hazardous wastes.
Hazardous Wastes from Nonspecific
Sources (40 CFR §261.31)
Hazardous wastes are also generated from nonspecific
sources, depending upon the type of waste. Table 11.2.1
lists a number of these categories, although it is by no
means an exhaustive listing.
—Mary A. Evans
William C. Zegel
Reference
Code of Federal Regulations.(1 July 1981): Title 40, sec. 261.3.
©1999 CRC Press LLC
It is virtually impossible to describe a “typical” hazardous
waste site, as they are extremely diverse. Many are mu-
nicipal or industrial landfills. Others are manufacturing
plants where operators improperly disposed of wastes.
Some are large federal facilities dotted with contamination
from various high-tech or military activities.
While many sites are now abandoned, some sites are

partially closed down or still in active operation. Sites range
dramatically in size, from quarter-acre metal plating shops
to 250-sq mi mining areas. The wastes they contain vary
widely, too. Chief constituents of wastes in solid, liquid, and
sludge forms include heavy metal, a common by-product of
electroplating operations, and solvents or degreasing agents.
Human Health Hazards
Possible effects on human and environmental health also
span a broad spectrum. The nearly uninhibited movement,
activity, and reactivity of hazardous chemicals in the at-
mosphere are well established, and movement from one
medium to another is evident. Hazardous wastes may en-
ter the body through ingestion, inhalation, dermal ab-
sorption, or puncture wounds.
Human health hazards occur because of the chemical
and physical nature of the waste, and its concentration and
quantity; the impact also depends on the duration of ex-
posure. Adverse effects on humans range from minor tem-
11.3
EFFECTS OF HAZARDOUS WASTE
©1999 CRC Press LLC
TABLE 11.3.1HEALTH EFFECTS OF SELECTED HAZARDOUS SUBSTANCES
Chemical Source Health Effects
Pesticides
DDT Insecticides Cancer; damage to liver, embryos, bird eggs
BHC Insecticides Cancer, embryo damage
Petrochemicals
BENZENE Solvents, pharmaceuticals Headaches, nausea, loss of muscle coordination, leukemia,
and detergents damage to bone marrow
VINYL CHLORIDE Plastics Lung and liver cancer, depression of central nervous

system, suspected embryotoxin
Other Organic
Chemicals
DIOXIN Herbicides, waste incineration Cancer, birth defects, skin disease
PCBs Electronics, hydraulic fluid, Skin damage, possible gastro-intestinal damage,
fluorescent lights possibly cancer-causing
Heavy Metals
LEAD Paint, gasoline Neurotoxic; causes headaches, irritability, mental impairment
in children; brain, liver, and kidney damage
CADMIUM Zinc, batteries, fertilizer Cancer in animals, damage to liver and kidneys
Source:World Resources Institute and International Institute for Environment and Development, 1987; World Resources 1987,(New York, N.Y.: Basic Books, pp.
205–06.
TABLE 11.3.2SITE SAFETY PLANS
• Name key personnel and alternates responsible for site safety.
•Describe the risks associated with each operation conducted.
•Confirm that personnel are adequately trained to perform their job responsibilities and to handle the specific hazardous situations
they may encounter.
•Describe the protective clothing and equipment to be worn by personnel during various site operations.
•Describe any site-specific medical surveillance requirements.
•Describe the program for periodic air monitoring, personnel monitoring, and environmental sampling, if needed.
•Describe the actions to be taken to mitigate existing hazards (e.g., containment of contaminated materials) to make the work en-
vironment less hazardous.
•Define site control measures and include a site map.
•Establish decontamination procedures for personnel and equipment.
•Set forth the site’s standard operating procedures for those activities that can be standardized, and where a checklist can be used.
•Set forth a contingency plan for safe and effective response to emergencies.
porary physical irritation, dizziness, headaches, and nausea
to long-term disorders, cancer or death. For example, the
organic solvent carbon tetrachloride (CCl
4

) is a central nerve
system depressant as well as an irritant and can cause ir-
reversible liver or kidney damage. Table 11.3.1 shows the
potential effects of selected hazardous substances.
Site Safety
Transportation spills and other industrial process or stor-
age accidents account for some hazardous waste releases.
Such releases can result in fires, explosions, toxic vapors,
and contamination of groundwater used for drinking.
Danger arises from improper handling, storage, and dis-
posal practices (refer to Section 11.11 on Treatment,
Storage, and Disposal Requirements). At hazardous waste
sites, fires and explosions may result from investigative or
remedial activities such as mixing incompatible contents
of drums or from introduction of an ignition source, such
as a spark from equipment.
A site safety plan is needed to establish policies and
procedures for protecting workers and personnel during
clean-up and day-to-day waste-handling activities. The
minimum contents of a site safety plan are listed in Table
11.3.2.
©1999 CRC Press LLC
TABLE 11.3.3 ENVIRONMENTAL PERFORMANCE GUIDELINES
Prevention of adverse effects on air quality considering
1. Volume and physical and chemical characteristics of facility waste, including potential for volatilization and wind dispersal
2. Existing quality of the air, including other sources of contamination and their cumulative impact on the air
3. Potential for health risks caused by human exposure to waste constituents
4. Potential damage to wildlife, crops, vegetation, and physical structures caused by exposure to waste constituents
5. Persistence and permanence of the potential adverse effects
Prevention of adverse effects on surface water quality considering

1. Volume and physical and chemical characteristics of facility waste
2. Hydrogeological characteristics of the facility and surrounding land, including topography of the area around the facility
3. Quantity, quality, and directions of groundwater flow
4. Patterns of rainfall in the region
5. Proximity of facility to surface waters
6. Uses of nearby surface waters and any water quality standards established for those surface waters
7. Existing quality of surface water, including other sources of contamination and their cumulative impact on surface water
8. Potential for health risks caused by human exposure to waste constituents
9. Potential damage to wildlife, crops, vegetation, and physical structures caused by exposure to waste constituents
10. Persistence and permanence of the potential adverse effects
Prevention of adverse effects on groundwater quality considering
1. Volume and physical and chemical characteristics of the waste in the facility, including its potential for migration through soil
or through synthetic liner materials
2. Geologic characteristics of the facility and surrounding land
3. Patterns of land use in the region
4. Potential for migration of waste constituents into subsurface physical structures
5. Potential for migration of waste constituents into the root zone of food-chain crops and other vegetation
6. Potential for health risks through human exposure to waste constituents
7. Potential damage to wildlife, crops, vegetation, and physical structures through exposure to waste constituents
8. Persistence and permanence of potential adverse effects
Particulates, Combustion Products
Particulates, Combustion Products
Volatile Reaction
Products
Volatile Components
Diffuse Through
Soil Pores
Products
Volatile Decomposition
Volatile

Reactive
Biodegradable
Water-
reactive
Fires
Explosions
Spontaneous
Combustion
Water-Soluble
Reaction Products
Soluble
Decomposition Products
Migrates to Atmosphere
Migrates Laterally Underground
Precipitation
Surface Water
Groundwater
Chemical Reactions
with Other
Waste Materials
Aerobic and/or
Anaerobic
Decomposition
Soluble Components
Infiltrated Water from
Leachate
Travels to Groundwater
or Seeps to Surface
Waste Carried as
Particulate Matter

in Surface Flows
W
A
S
T
E
FIG. 11.3.1 Initial transport processes at waste disposal sites (EPA).
©1999 CRC Press LLC
Characterization, Sampling,
and Analysis
11.4
HAZARDOUS WASTE CHARACTERIZATION
Criteria
The EPA applies two criteria in selecting four characteris-
tics as inherently hazardous in any substance:
The characteristics must be listed in terms of physical,
chemical, or other properties causing the waste to meet
the definition of a hazardous waste in the act; and
The properties defining the characteristics must be mea-
surable by standardized, available testing protocols.
The second criterion was adopted because generators
have the primary responsibility for determining whether
a solid waste exhibits any of the characteristics. EPA
regulation writers believed that unless generators were
provided with widely available and uncomplicated
methods for determining whether their wastes exhibited
the characteristics, the identification system would not
work (U.S. EPA 1990).
Because of this second criterion, the EPA did not add
carcinogenicity, mutagenicity, bioaccumulation potential,

or phytotoxicity to the characteristics. The EPA consid-
ered the available protocols for measuring these charac-
teristics either insufficiently developed, too complex, or too
highly dependent on skilled personnel and professional
equipment. In addition, given the current knowledge of
such characteristics, the EPA could not confidently define
the numerical threshold levels where characteristic wastes
would present a substantial hazard (U.S. EPA 1990).
Characteristics
As testing protocols become accepted and confidence in
setting minimum thresholds increases, more characteristics
may be added. To date, waste properties exhibiting any
or all of the existing characteristics are defined in 40 CFR
§261.20–261.24.
Environmental Contamination
Hazardous waste disposers need to understand the poten-
tial toxic effects of these wastes and realize how strictly
the wastes must be contained. Dangerous chemicals often
migrate from uncontrolled sites, percolating from holding
ponds and pits into underlying groundwater, then flowing
into lakes, streams, and wetlands. Produce and livestock
in turn become contaminated, then enter the food chain.
Hazardous chemicals then build up, or bioaccumulate,
when plants, animals, and people consume contaminated
food and water.
Most groundwater originates as surface water. Great
quantities of land-deposited hazardous wastes evaporate
into the atmosphere, runoff to surface waters, then per-
colate to groundwaters (Figure 11.3.1). Atmospheric and
surface water waste releases commingle with other releases

or are lost to natural processes, but groundwater conta-
mination may remain highly concentrated, relatively lo-
calized, and persistent for decades or centuries. Although
current quantities of waste are being reduced, any addi-
tional releases together with previously released materials
will continue contaminating aquifers in many areas, and
many groundwater supplies are now impaired.
Table 11.3.3 presents EPA guidelines for hazardous
handling facilities performance with respect to human
health and the environment.
—David H.F. Liu
References
U.S. Environmental Protection Agency (U.S. EPA). 1981. Interim stan-
dard for owners and operators of new hazardous waste land disposal
facilities.Code of Federal Regulations. Title 40, Part 267.
Washington, D.C.: U.S. Government Printing Office.
———. 1985. Protecting health and safety at hazardous waste sites: an
overview.Technology Transfer, EPA 625/9–25/006, Cincinnati, OH.
CHARACTERISTIC OF IGNITABILITY
Ignitability is the characteristic used to define as hazardous
those wastes that could cause a fire during transport, stor-
age, or disposal. Examples of ignitable wastes include
waste oils and used solvents.
A waste exhibits the characteristics of ignitability if a
representative sample of the waste has any of the follow-
ing properties:
1. It is a liquid, other than an aqueous solution con-
taining less than 24% alcohol by volume, and has
flash point less than 60°C (140°F), as determined
by a Pensky-Martens Closed Cup Tester (using the

test method specified in ASTM Standard D-93-79
or D-93-80) or by a Setaflash Closed Cup Tester
(using the test method specified in ASTM Standard
D-3278-78).
2. It is not a liquid and is capable, under standard tem-
perature and pressure, of causing fire through friction,
absorption of moisture, or spontaneous chemical
changes and, when ignited, burns so vigorously and per-
sistently that it creates a hazard.
3. It is an ignitable compressed gas as defined in the 49
Code of Federal Regulations 173.300 DOT regulations.
4. It is an oxidizer as defined in the 49 Code of Federal
Regulations 173.151 DOT regulations.
A waste that exhibits the characteristic of ignitability
but is not listed as a hazardous waste in Subpart D of
RCRA has the EPA hazardous waste number of D001.
CHARACTERISTIC OF CORROSIVITY
Corrosivity, as indicated by pH, was chosen as an identi-
fying characteristic of a hazardous waste because wastes
with high or low pH can react dangerously with other
wastes or cause toxic contaminants to migrate from cer-
tain wastes. Examples of corrosive wastes include acidic
wastes and used pickle liquor from steel manufacture. Steel
corrosion is a prime indicator of a hazardous waste since
wastes capable of corroding steel can escape from drums
and liberate other wastes.
A waste exhibits the characteristic of corrosivity if a
representative sample of the waste has either of the fol-
lowing properties:
1. It is aqueous and has a pH less than or equal to 2 or

greater than or equal to 11.5, as determined by a pH
meter using an EPA test method. The EPA test method
for pH is specified as Method 5.2 in “Test Methods for
the Evaluation of Solid Waste, Physical/Chemical
Methods.”
2. It is a liquid and corrodes steel (SAE 1020) at a rate
greater than 6.35 mm (0.250 inch) per year at a test
temperature of 55°C (130°F), as determined by the test
method specified in NACE (National Association of
Corrosion Engineers) Standard TM-01-69 and stan-
dardized in “Test Methods for the Evaluation of Solid
Waste, Physical/Chemical Methods.”
A waste that exhibits the characteristic of corrosivity
but is not listed as a hazardous waste in Subpart D has
the EPA hazardous waste number of D002.
CHARACTERISTIC OF REACTIVITY
Reactivity was chosen as an identifying characteristic of a
hazardous waste because unstable wastes can pose an ex-
plosive problem at any stage of the waste management cy-
cle. Examples of reactive wastes include water from TNT
operations and used cyanide solvents.
A waste exhibits the characteristic of reactivity if a rep-
resentative sample of the waste has any of the following
properties:
1. It is normally unstable and readily undergoes violent
change without detonating.
2. It reacts violently with water.
3. It forms potentially explosive mixtures with water.
4. When mixed with water, it generates toxic gases, va-
pors, or fumes in a quantity sufficient to present a dan-

ger to human health or the environment.
5. It is a cyanide- or sulfide-bearing waste which, when
exposed to pH conditions between 2 and 11.5, can gen-
erate toxic gases, vapors, or fumes in a quantity suffi-
cient to present a danger to human health or the envi-
ronment.
6. It is capable of detonation or explosive reaction if sub-
jected to a strong initiating source or if heated under
confinement.
7. It is readily capable of detonation or explosive decom-
position or reaction at standard temperature and pres-
sure.
8. It is a forbidden explosive as defined in the 49 Code of
Federal Regulations 173.51, or a Class A explosive as
defined in the 49 Code of Federal Regulations 173.53,
or a Class B explosive as defined in the 49 Code of
Federal Regulations 173.88 DOT regulations.
A waste that exhibits the characteristic of reactivity but
is not listed as a hazardous waste in Subpart D has the
EPA hazardous waste number of D003.
CHARACTERISTIC OF TOXICITY
The test, toxicity characteristic leaching procedure (TCLP),
is designed to identify wastes likely to leach hazardous con-
centrations of particular toxic constitutents into the
groundwater as a result of improper management. During
the TCLP, constituents are extracted from the waste to
stimulate the leaching actions that occur in landfills. If the
concentration of the toxic constituent exceeds the regula-
tory limit, the waste is classified as hazardous.
©1999 CRC Press LLC

If the extract from a representative waste sample con-
tains any of the contaminants listed in Table 11.4.1 at a
concentration equal to or greater than the respective value
given, the waste exhibits the toxicity characteristic. Where
the waste contains less than 0.5 percent filterable solids,
the waste itself is considered to be the extract. A waste
that exhibits the toxicity characteristic but is not a listed
hazardous waste has the EPA hazardous waste number
specified in Table 11.4.1. The TCLP test replaced the EP
toxicity test in September 1990 and added 25 organic com-
pounds to the eight metals and six pesticides that were
subject to the EP toxicity test.
Specific Compounds
Information about waste is needed to evaluate the health
effects, determine the best method of handling, and eval-
uate methods of storage, treatment or disposal. Items of
interest include:

Physical properties such as density or viscosity

Toxicity in water

Permissible exposure limits (PELs) in the air

Health hazards

Precautions

Controls


Emergency and first aid procedures

Disposal methods
There are a number of references that define the proper-
ties of specific compounds (Sax 1984, Sittig 1985, Weiss
1986), however, no current source defines the impact of
hazardous mixtures.
—David H.F. Liu
References
Sax, N. 1984. Dangerous properties of hazardous materials.6th ed. New
York, N.Y.: Van Nostrand Reinhold.
Sittig, M. 1985. Handbook of toxic and hazardous chemicals and car-
cinogens.2d ed. Park Ridge, N.J.: Noyes Publications.
U.S. Environmental Protection Agency (EPA). 1990. RCRA orientation
manual.Office of Solid Waste. Washington, D.C.
Weiss, G. 1986. Hazardous chemical data book.2d ed. Park Ridge, N.J.:
Noyes Publications.
©1999 CRC Press LLC
TABLE 11.4.1MAXIMUM CONCENTRATION OF CONTAMINANTS FOR RCRA TOXICITY CHARACTERISTICS
EPA EPA
Hazardous Maximum Hazardous Maximum
Waste Concentration Waste Concentration
Number Contaminant (mg/L) Number Contaminant (mg/L)
D004 Arsenic
a
5.0 D036 Hexachloro-1,3- 0.5
D005 Barium
a
100.0 butadiene
D019 Benzene 0.5 D037 Hexachloroethane 3.0

D006 Cadmium
a
1.0 D008 Lead
a
5.0
D022 Carbon tetrachloride 0.5 D013 Lidane
a
0.4
D023 Chlordane 0.03 D009 Mercury
a
0.2
D024 Chlorobenzene 100.0 D014 Methoxychlor
a
10.0
D025 Chloroform 6.0 D040 Methyl ethyl ketone 200.0
D007 Chromium 5.0 D041 Nitrobenzene 2.0
D026 o-Cresol 200.0 D042 Pentachlorophenol 100.0
D027 m-Cresol 200.0 D044 Pyridine 5.0
D028 p-Cresol 200.0 D010 Selenium 1.0
D016 2,4-D
a
10.0 D011 Silver
a
5.0
D030 1,4-Dichloroben- 7.5 D047 Tetrachloroethylene 0.7
zene D015 Toxaphene
a
0.5
D031 1,2-Dichloroethane 0.5 D052 Trichloroethylene 0.5
D032 1,1-Dichloroethy- 0.7 D053 2,4,5-Trichloro- 400.0

lene phenol
D033 2,4-Dinitrotoluene 0.13 D054 2,4,6-Trichloro- 2.0
D012 Endrin
a
0.02 phenol
D034 Heptachlor (and its 0.008 D017 2,4,5-TP (Silvex)
a
1.0
hydroxide) D055 Vinyl chloride 0.2
D035 Hexachlorobenzene 0.13
a
Formerly EP Toxicity Contaminants.
Source: Code of Federal Regulations,Title 40, sec. 261.24.
Safety and data quality are the two major concerns when
sampling hazardous waste. Where environmental data are
collected, quality assurance provides the means to deter-
mine data quality. This entails planning, documentation
and records, audits, and inspections. Data quality is known
when there are verifiable and defensible documentation
and records associated with sample collection, trans-
portation, sample preservation and analysis, and other
management activities.
Sampling Equipment and Procedures
SAFETY
Samples must be secured in a manner ensuring the safety
of the sampler, all others working in the area, and the sur-
roundings.
If the source and nature of the hazardous waste are
known, the sampler should study the properties of the
material to determine the necessary safety precautions,

including protective clothing and special handling pre-
cautions.
If the nature of the hazardous waste is unknown, such as
at an abandoned waste disposal site, then the sampler
should take additional precautions to prevent direct
contact with the hazardous waste. Stored, abandoned,
or suspect waste will often be containerized in drums
and tanks. Such containers and materials buried under
abandoned waste sites pose special safety problems (De
Vera, Simmons, Stephens, Storn, 1980; EPA 1985).
Care must be exercised in opening drums or tanks to
prevent sudden releases of pressurized materials, fire,
explosions, or spillage.
SAMPLING EQUIPMENT
Drums should be opened using a spark-proof brass bung
wrench. Drums with bulged heads are particularly dan-
gerous. The bulge indicates that the contents are under ex-
treme pressure. To sample a bulged drum, a remotely op-
erated drum opening device should be used, enabling the
sampler to open the drum from a safe distance. Such op-
erations should be carried out only by fully trained tech-
nicians in full personnel protective gear.
Liquid waste in tanks must be sampled in a manner
that represents the contents of the tank. The EPA specifies
that the colawassa sampler is used for such sampling. The
colawassa is a long tube with a stopper at the bottom that
opens or closes using the handle at the top. This device
enables the sampler to retrieve representative material at
any depth within the tank. The colawassa has many short-
comings, including the need for completely cleaning it and

removal of all residues between each sampling. This is dif-
ficult, and it also creates another batch of hazardous waste
to be managed.
A glass colawassa, which eliminates sample contami-
nation by metals and stopper materials, is available
through technical and scientific supply houses. In most sit-
uations, ordinary glass tubing can be used to obtain a rep-
resentative sample, and can be discarded after use.
Bomb samplers that are lowered into a liquid waste con-
tainer, then opened at the selected depth, are also useful
in special situations.
Long-handled dippers can be used to sample ponds, im-
poundments, large open tanks, or sumps: however these
devices cannot cope with stratified materials. Makeshift
devices using tape or other porous or organic materials in-
troduce the likelihood of sample contamination.
Dry solid samples may be obtained using a thief or trier,
or an augur or dipper. Sampling of process units, liquid
discharges, and atmospheric emissions all require special-
ized equipment training.
The EPA has published several guidance documents de-
tailing hazardous waste, soil, surface water and ground-
water and waste stream sampling (EPA 1985a, 1985b; De
Vera et al. 1980; Evans and Schweitzer 1984).
Procedures used or materials contacting the sample
should not cause gain or loss of pollutants. Sampling equip-
ment and sample containers must be fabricated from in-
ert materials and must be thoroughly cleaned before use.
Equipment that comes into contact with samples to be an-
alyzed for organic compounds should be fabricated of (in

order of preference):

Glass (amber glass for organics; clear glass for
metals, oil, cyanide, BOD, TOC, COD, sludges,
soil, and solids, and others)

Teflon (Teflon lid liners should be inserted in caps
to prevent contamination normally supplied with
bottles)

Stainless steel

High-grade carbon steel

Polypropylene

Polyethylene (for common ions, such as fluoride,
chloride, and sulfate)
©1999 CRC Press LLC
11.5
SAMPLING AND ANALYSIS
Classic commercial analytic schedules require a sample of
more than 1,500ml. Commercial field samplers collect
samples of 500 to 1,000ml. If such volumes are insuffi-
cient, multibottle samples can be collected. Special con-
tainers may be designed to prolong sample duration.
PROCEDURES
Representative samples should be obtained to determine
the nature of wastes.
If the waste is in liquid form in drums, it should be com-

pletely mixed (if this is safe) before sampling, and an
aliquot should be taken from each container. Within a
group of drums containing similar waste, random sam-
pling of 20% of the drums is sufficient to characterize
the wastes. If the sampler is unsure of the drum con-
tents, each must be sampled and analyzed.
If the waste source is a manufacturing or waste treatment
process solid, composite sampling and analysis are rec-
ommended. In such cases, an aliquot is periodically col-
lected, composited, and analyzed.
If the solid waste is in a lagoon, abandoned disposal fa-
cility, tank, or similar facility, three-dimensional sam-
pling is recommended. Although samples collected
three-dimensionally are sometimes composited, they are
usually analyzed individually. This process character-
izes the solid waste and aids in determining whether the
entire quantity of material is hazardous.
If the source and nature of the material is known, sam-
pling and analysis are limited to the parameters of con-
cern. When the waste is unknown, a full analysis for
129 priority pollutants is often required.
SAMPLE PRESERVATION
Aqueous samples are susceptible to rapid chemical and
physical reactions between the sampling time and analy-
sis. Since the time between sampling and analysis could be
greater than 24 hours, the following preservation tech-
niques are recommended to avoid sample changes result-
ing in errors: all samples except metals must be refriger-
ated. Refrigeration of samples to 4°C is common in
fieldwork, and helps stabilize samples by reducing biolog-

ical and chemical activity (EPA 1979).
In addition to refrigeration, specific techniques are re-
quired for certain parameters (see section 10.9). The
preservation technique for metals is the addition of nitric
acid (diluted 1:1) to adjust the pH to less than 2, which
will stabilize the sample up to 6 months; for cyanide, the
addition of 6N caustic will adjust the pH to greater than
12, and refrigeration to 4°C, which will stabilize the sam-
ple for up to 14 days. Little other preservation can be per-
formed on solid samples.
Quality Assurance and Quality Control
Quality assurance has emerged significantly during the past
decade. Permit compliance monitoring, enforcement, and
litigation are now prevalent in the environmental arena.
Only documented data of known quality will be sustained
under litigation. This section focuses on two areas.
SAMPLE CUSTODY
Proper chain-of-custody procedures allow sample pro-
cessing and handling to be traced and identified from the
time containers are initially prepared for sampling to the
final disposition of the sample. A chain-of-custody record
(Figure 11.5.1) should accompany each group of samples
from the time of collection to their destination at the an-
alytical laboratory. Each person with custody of the sam-
ples must sign the chain-of-custody form, ensuring that the
samples are not left unattended unless properly secured.
Within the laboratory, security and confidentiality of
all stored material should always be maintained. Analysts
should sign for any sample removed from a storage area
for performing analyses and note the time and date of re-

turning a sample to storage. Before releasing analytical re-
sults, all information on sample labels, data sheets, track-
ing logs, and custody records should be cross-checked to
ensure that data are consistent throughout the record.
Gummed paper custody seals or custody tape should be
used to ensure that the seal must be broken when open-
ing the container.
©1999 CRC Press LLC
FIG. 11.5.1Example chain of custody record. Distribution:
Original—accompany shipment; One copy—survey coordinator-
field files.
CHAIN OF CUSTODY RECORD
PROJECT
SAMPLERS:
(Signed)
LAB #
STATION
DATE
TIME
REMARKS
NUMBER
OF
CONTAINERS
OTHER
OIL
AIR
TISSUE
SEDIMENT
WATER
SAMPLE TYPE

RELINQUISHED BY:
(Signed)
RECEIVED BY:
(Signed)
DATE/TIME
RECV'D BY MOBILE LAB FOR FIELD
ANAL.:
(Signed)
DISPATCHED BY:
(Signed)
RECEIVED FOR LAB BY:
(Signed)
METHOD OF SHIPMENT:
DATE/TIME DATE/TIME
RELINQUISHED BY:
(Signed)
RECEIVED BY:
(Signed)
DATE/TIME
RELINQUISHED BY:
(Signed)
RECEIVED BY:
(Signed)
DATE/TIME
RELINQUISHED BY:
(Signed)
DATE/TIME
PRECISION AND ACCURACY
One of the objectives of the QA or QC plan is to ensure
that there is no contamination from initial sampling through

final analysis. For this reason, duplicate, field blank, and
travel blank samples should be prepared and analyzed.
Duplicate sampling requires splitting one field sample into
two aliquots for laboratory analysis. Typically, 10% of
the samples should be collected in duplicate. Duplicates
demonstrate the reproducibility of the sampling proce-
dure.
A travel blank is a contaminant-free sample prepared in the
laboratory that travels with empty sample bottles to the
sampling site and returns to the laboratory with the
samples. Typically, two travel blanks are prepared and
shipped. Travel blanks identify contamination in the prep-
aration of sample containers and shipping procedures.
Field blanks are empty sampling bottles prepared using
contaminant-free water following general field sampling
procedures for collection of waste samples. These are
returned to the laboratory for analysis. Field blanks
identify contamination associated with field sampling
procedures.
For liquid samples, all three types of the above QA/QC
samples are prepared. For soils, semi-soils, sludges, and
solids, only duplicate samples are typically prepared.
The field supervisor of sample collection should main-
tain a bound logbook so that field activity can be com-
pletely reconstructed without relying on the memory of the
field crew. Items noted in the logbook should include:

Date and time of activity

Names of field supervisor and team members


Purpose of sampling effort
©1999 CRC Press LLC
Volatile Organics
acrolein
acrylonitrile
benzene
bis(chloromethyl)ether
bromoform
carbon tetrachloride
chlorobenzene
chlorodibromomethane
pentachlorophenol
2-chloroethyl vinyl ether
chloroform
dichlorobromomethane
1,2-dichloroethane
1,1-dichloroethane
1,1,-dichloroethylene
1,2-dichloropropane
1,2-dichloropropylene
ethylbenzene
methyl bromide
methyl chloride
methylene chloride
1,1,2,3-tetrachloroethane
tetrachloroethylene
toluene
1,2-trans-dichloroethylene
1,1,1-trichloroethane

1,1,2-trichloroethane
trichloroethylene
vinyl chloride
Acid-Extractable Organics
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2-nitrophenol
4-nitrophenol
parachlorometacresol
1,2,4-trichlorobenzene
phenol
2,4,6-trichlorophenol
Base and Neutral Organics
acenaphthene
acenaphtylene
anthracene
benzidine
benzo(a)anthracene
benzo(a)pyrene
benzo(ghi)perylene
benzo(k)fluoranthene
3,4-benzo-fluoranthene
bis(2-chloroethoxy) methane
bis(2-chloroethyl)ether
bis(2-chloroisopropyl)-
ether
bis(2-ethylhexyl)phthalate
4-bromophenyl phenyl

ether
butyl benzyl phthalate
2-chloro-naphthalene
4-chlorophenyl phenyl
ether
chrysene
di-n-butyl phthalate
di-n-octyl phthalate
dibenzo(a,h)anthracene
1,2-dichlorobenzene
4,4Ј-DDT
1,4-dichlorobenzene
diethyl phthalate
dimethyl phthalate
2,4-dinitrotoluene
2,6-dinitrotoluene
1,2-diphenylhyrazine
fluoranthene
fluorene
hexachlorobenzene
hexachlorobutadiene
hexachlorocyclo-
pentadiene
hexachloroethane
indeno(1,2,3-cd)-pyrene
isophorone
naphthalene
nitrobenzene
N-nitrosodi-n-
propylamine

N-nitrosodimethylamine
N-nitrosodiphenylamine
phenathrene
pyrene
2,3,7,8-tetrachloro-
dibenso-p-dioxin
Pesticides and PCBs
aldrin
alpha-BHC
beta-BHC
gamma-BHC
delta-BHC
chlordane
4,4Ј-DDD
4,4Ј-DD chloroethane
dieldrin
alpha-endosulfan
beta-endosulfan
endosulfan sulfate
endrin
endrin aldehyde
heptachlor
heptachlor epoxide
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260

toxaphene
Metals
antimony
arsenic
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
thallium
zinc
Cyanides
Asbestos
TABLE 11.5.1 CATEGORIZATION OF PRIORITY POLLUTANTS
Source: Reprinted from U.S. Environmental Protection Agency (EPA), 1980–1988, National Pollutant Discharge Elimination System, Code of Federal Regulations,
Title 40, Part 122. (Washington, D.C.: U.S. Government Printing Office).

Description of sampling site

Location of sampling site

Sampling equipment used

Deviation(s) from standard operating procedures

Reason for deviations


Field observations

Field measurements

Results of any field measurements

Sample identification

Type and number of samples collected

Sample handling, packaging, labeling, and ship-
ping information
The logbook should be kept in a secure place until the pro-
ject activity is completed, when the logbook should be kept
in a secured project file.
Analysis
If the source and nature of the waste is known, sampling
and analysis are limited to the parameters of concern. If
the waste is unknown, a full spectrum analysis is often re-
quired, including analysis for the 129 priority pollutants.
Table 11.5.1 divides priority pollutants into seven cate-
gories (EPA 1980–1988).
Table 11.5.2 presents the recommended analytical
procedures for the following categories: volatile organics,
acid-extractable organics, base and neutral organics,
pesticides and PCBs, metals, cyanides, asbestos, and
others. Typically, organic analysis is performed using
gas chromatography and mass spectrometry (GC/MS).
Typical sensitivity is on the order of 1–100 parts per

billion (ppb), depending on the specific organic com-
pound and the concentration of compounds that may
interfere with the analysis. This technique gives good
quantification and excellent qualification about the
organics in the waste.
A number of references should be consulted before de-
termining the analytical protocols for the waste sample
(EPA 1979; EPA 1977; EPA 1985a; EPA 1979a; APHA
1980).
Because analysis of hazardous waste samples is costly,
it is beneficial to prepare several samples and subject them
to one of several screening procedures. Depending on the
data obtained, the analytical program can then focus on
the major constituents of concern, resulting in cost sav-
ings. Recommended screening tests include: pH; conduc-
tivity; total organic carbon (TOC); total phenols; organic
scan (via GC with flame ionization detector); halogenated
(via GC with electron capture detector); volatile organic
©1999 CRC Press LLC
TABLE 11.5.2RECOMMENDED METHOD FOR ANALYSIS
Analytical Category Recommended Method for Analysis*
Volatile organics GC/MS (USEPA Method 624)
Acid-extractable organics GC/MS (USEPA Method 625)
Base and neutral organics GC/MS (USEPA Method 625)
TCDD (dioxin) GC/MS (USEPA Method 608)
Pesticides and PCBs GC/MS (USEPA Method 625)
Metals Atomic absorption (flame or graphite)†
Mercury Cold vapor atomic absorption spectroscopy
Cyanide EPA colorimetric method
Asbestos Fibrous asbestos method

Anions (SO
4

, F
Ϫ
, Cl
Ϫ
) Ion chromatography
Oil and grease Freon extraction and gravimetric measurement
Purgeable halocarbons GC (USEPA Method 601)
Purgeable aromatics GC (USEPA Method 602)
Acrolein and acrylonitrile GC (USEPA Method 603)
Phenols GC (USEPA Method 604)
Benzidine GC (USEPA Method 605)
Pthalate esters GC (USEPA Method 606)
Nitrosamines GC (USEPA Method 607)
Pesticides and PCBs GC (USEPA Method 608)
Nitroaromatics and isophorone GC (USEPA Method 609)
Polynuclear aromatic hydrocarbons GC (USEPA Method 610)
Chlorinated hydrocarbons GC (USEPA Method 611)
TCDD (dioxin screening) GC (USEPA Method 612)
*GC/MS ϭgas chromatography/mass spectrometry; GC ϭgas chromatography.
†Graphite furnace is a more sensitive technique.
Source:Reprinted from U.S. EPA, 1980–1988.
scan; nitrogen-phosphorous organic scan; and metals (via
inductively coupled plasma or atomic emission spec-
troscopy).
—David H.F. Liu
References
American Public Health Association (APHA). 1980. Standard methods

for the examination of water and wastewater.15th ed. APFA. New
York, N.Y.
De Vera, E.R., B.P. Simmons, R.D. Stephens, and D.L. Storn, 1980.
Samplers and sampling procedures in hazardous waste streams.EPA
600–2–80–018, Cincinnati, Oh.
Evans, R.B., and G.E. Schweitzer. 1984. Assessing hazardous waste prob-
lems, Environmental science and technology.18(11).
U.S. Environmental Protection Agency (EPA). 1977. Sampling and analy-
sis procedure for screening of industrial effluent for priority pollu-
tants.Effluent Guideline Division. Washington, D.C.
———. 1979. Method for chemical analysis of water and waste.EPA
600–4–79–020. Washington, D.C.
———. 1979a. Guidelines establishing procedures for analysis of pollu-
tants.Code of Federal Regulations, Title 40, Part 136. Washington,
D.C.: U.S. Government Printing Office.
———. 1980–1988. National pollutant discharge elimination system.
Code of Federal Regulations, Title 40, Part 122. Washington, D.C.:
U.S. Government Printing Office.
———. 1985. Protecting health and safety at hazardous waste sites: an
overview,Technology Transfer EPA, 625–9–85–006. Cincinnati, Oh.
———. 1985a. Characterization of hazardous waste sites—a methods
manual; vol II, available sampling methods.EPA 600–4–84–075.
Washington, D.C.
———. 1985b. Test methods for evaluating solid waste, physical/chem-
ical methods.2d ed. SW-846. Washington, D.C.
©1999 CRC Press LLC
11.6
COMPATIBILITY
Wasteloads are frequently consolidated before transport
from point of generation to point of treatment or disposal.

Accurate waste identification and characterization is nec-
essary to:

Determine whether wastes are hazardous as de-
fined by regulations

Establish compatibility grouping to prevent mix-
ing incompatible wastes

Identify waste hazard classes as defined by the
Department of Transportation (DOT) to enable
waste labeling and shipping in accordance with
DOT regulations

Provide identification to enable transporters or
disposal operators to operate as prescribed by reg-
ulations.
Most wastes are unwanted products of processes involv-
ing known reactants. Thus, the approximate compositions
of these wastes are known. Wastes of unknown origin must
undergo laboratory analysis to assess their RCRA status,
including testing for the hazardous properties of ignitabil-
ity, reactivity, corrosivity, or toxicity in accordance with
methods specified in the regulations (See Section 11.4).
Once a waste is identified, it is assigned to a compati-
bility group. One extensive reference for assigning groups
is a study of hazardous wastes performed for the EPA by
Hatayama et al (1980). A waste can usually be placed eas-
ily in one of the groups shown in Figure 11.6.1, based on
its chemical or physical properties. The compatibility of

various wastes is shown in Figure 11.6.1, which indicates
the consequences of mixing incompatible wastes.
Complete compatibility analysis should be carried out by
qualified professionals to ascertain whether any waste can
be stored safely in proximity to another waste.
—William C. Zegel
Reference
Hatayama et al. 1980. A method for determining the compatibility
of hazardous wastes.U.S. Environmental Protection Agency (EPA).
Office of Research and Development. EPA 600–2–80–076.
Cincinnati, Oh.
FIG. 11.6.1 Hazardous waste compatibility chart. (Reprinted from Hatayama et al. 1980, A method for determining the compat-
ibility of hazardous wastes, U.S. Environmental Protection Agency [EPA] [Office of Research and Development. EPA 600–2–80–076,
Cincinnati, Oh].)
Reactivity
group no.
Reactivity group name
1
2
3
4
5
6
7
8
9
10
11
12
13

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
101
102
103
104
105
106
107
H
GF

F
Acids, mineral, nonoxidizing
Acids, mineral, oxidizing
Acids, organic
Alcohols and glycols
Aldehydes
Amides
Amines, aliphatic and aromatic
Azo compounds, diazo compounds, and hydrazines
Carbamates
Caustics
Cyanides
Dithiocarbamates
Esters
Ethers
Flourides, inorganic
Hydrocarbons, aromatic
Halogenated organics
Isocyanates
Ketones
Mercaptans and other organic sulfides
Metals, alkali and alkaline earth, elemental
Metals, other elemental & alloys as powders, vapors, or sponges
Metals, other elemental & alloys as sheets, rods, drops, moldings, etc.
Metals and metal compounds, toxic
Nitrides
Nitriles
Nitro compounds, organic
Hydrocarbons, aliphatic, unsaturated
Hydrocarbons, aliphatic, saturated

Peroxides and hydroperoxides, organic
Phenols and cresols
Organophosphates, phosphothioates, phosphodithioates
Sulfides, inorganic
Epoxides
Combustible and flammable materials, miscellaneous
Explosives
Polymerizable compounds
Oxidizing agents, strong
Reducing agents, strong
Water and mixtures containing water
Water reactive substances
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 101 102 103 104 105 106 107
107
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
101
102
103
104
105
106
H
P
H
F
G
H

H
P
H
F
H
GT
H
GT
H
GT
H
GT
H
GT
GF
H
F
H
F
GT
H
F
H
F
GT
H
F
GT
H
F

H
F
GT
GF
H
F
GF
H
F
GF
H
F
S
H
F
E
H
F
GT
H
F
GT
H
F
H
F
H
E
H
F

H
GT
HF
GT
H
P
H
F
GT
H
E
P
H
H
F
GT
H
H
H
P
H
H
G
H
H
GF
H
GT
P
H

P
H
H
E
H
E
H
G
H
P
GT
GF
H
GT
H
H
G
H
H
GT
GF
GF
HF
S
S
GF
H
F
GF
H

F
GF
H
F
GF
H
F
GF
H
F
GF
H
F
GF
GT
GF
H
H
G
H
GT
GT
GT
H
H
H
GF
F
GT
GF

H
H
H
G
H
H
G
H
GT
GF
H
GF
GT
H
G
GF
H
GF
H
GF
H
GF
H
GF
H
GF
H
GF
H
GF

GT
H
H
H
H
G
H
G
H
G
H
G
H
P
H
P
H
GT
H
GF
H
H
P
G
H
G
H
H
H
GF

GT
U
U
H
G
H
G
H
H
G
G
G
H
H
H
H
H
F
GT
H
F
G
U
S
S
S
H
G
U
GF

H
GF
H
GF
H
U
H
E
H
GF
GF
H
E
GF
H
H
H
H
F
H
G
H
GT
H
F
E
H
F
GT
H

G
U
E
H
P
H
E
P
H
H
E
H
G
G
H
GF
GF
H
GF
H
F
H
GF
H
GF
F
H
GT
H
F

H
F
H
F
GT
H
F
GT
H
P
H
P
U
H
P
H
P
H
P
U
H
GT
H
F
U
P
H
P
H
H

F
GT
H
E
GT
H
F
GT
H
F
H
F
H
F
H
E
H
E
H
E
H
F
GF
H
GF
H
GF
H
GF
H

H
GF
F
E
GF
H
GF
H
U
GF
H
H
P
H
GF
E
H
E
S
GF
H
H
GF
E
H
P
H
P
GT
H

GF
E
H
G
P
G
H
E
H
F
GT
E
H
H
E
H
E
GT
H
F
GT
H
P
GF
H
H
H
P
H
P

H
P
H
P
H
P
H
P
U
H
P
H
P
U
H
H
GT
H
E
H
E
H
E
H
E
H
E
EE
H
GF

E
H
G
F
H
E
H
E
H
E
P
H
P
H
P
H
P
H
P
H
H
F
E
H
F
H
F
E
H
F

E
H
F
H
F
GT
H
GT
H
F
GT
GF
H
GF
H
GF
H
H
G
GF
H
GF
H
S
GF
H
H
F
H
E

H
F
GT
H
G
H
F
H
F
GT
H
F
G
H
F
GT
H
F
G
H
E
H
F
GT
H
F
H
F
E
H

P
GF
H
E
GF
GT
GT
GF
H
E
GF
H
GT
GF
H
GF
H
H
H
E
P
H
P
H
P
H
H
F
GT
H

GF
H
E
GT
H
H
E
H
E
H
E
H
GF
H
H
U
GF
H
H
G
Reactivity Code
Consequences
Heat generation
Fire
Innocuous and nonflammable gas generation
Toxic gas generation
Flammable gas generation
Explosive
Violent polymerization
Solubilization of toxic substances

May be hazardous but unknown
Example:
Heat generation, fire, and
toxic gas generation
H
F
G
GT
GF
E
P
S
U
H
F
GT
EXTREMELY REACTIVE!
DO NOT MIX WITH ANY CHEMICAL OR WASTE MATERIAL!
EXTREMELY REACTIVE!
The Comprehensive Environmental Response, Compen-
sation, and Liability Act (CERCLA) of 1980, better known
as Superfund, became law “to provide for liability, com-
pensation, cleanup and emergency response for hazardous
substances released into the environment and the cleanup
of inactive hazardous waste disposal sites.” CERCLA was
intended to give the EPA authority and funds to clean up
abandoned waste sites and to respond to emergencies re-
lated to hazardous waste.
If a site poses a significant threat, the EPA uses its
Hazard Ranking System (HRS) to measure the relative risk.

Based upon this ranking system, sites warranting the high-
est priority for remedial action become part of the National
Priority List (NPL).
The HRS ranks the potential threat posed by facilities
based upon containment of hazardous substances, route
of release, characteristics and amount of substances, and
likely targets. HRS methodology provides a quantitative
estimate of the relative hazards posed by a site, taking into
account the potential for human and environmental ex-
posure to hazardous substances. The HRS score is based
on the probability of contamination from three sources—
groundwater, surface water, and air—on the site in ques-
tion. The HRS score assigned to a hazardous site reflects
the potential hazards relative to other sites (Hallstedt,
Puskar & Levine 1986).
S
M
is the potential for harm to humans or the environ-
ment from migration of a hazardous substance to
groundwater, surface water, or air; it is a composite of
scores of each of the three routes
S
FE
is the potential for harm from flammable or explosive
substances
S
DC
is the potential for harm from direct contact with haz-
ardous substances at the site
The score for each of these hazard modes is obtained from

a set of factors characterizing the facility’s potential to
cause harm as shown in Table 11.7.1. Each factor is as-
signed a numerical value according to the prescribed cri-
teria. This value is then multiplied by a weight factor, yield-
ing the factor score.
The factor scores are then combined: scores within a
factor category are added together, then the total scores
for each factor category are multiplied together. S
M
is
a composite of the scores of three possible migration
routes:
S
M
ϭ

1.
1
73

S
2
g

w

ϩ

S


2
sw

ϩ

S

2
a

11.7(1)
Figure 11.7.1 shows a typical worksheet for calculating
the score for groundwater. Other worksheets are included
in 40 CFR Part 300, Appendix A (1987).
Use of the HRS requires considerable information about
the site, its surroundings, the hazardous substances pre-
sent, and the geology in relation to the aquifers. If the data
are missing for more than one factor in connection with
the evaluation of a route, then that route score becomes
0, and there is no need to assign scores to factors in a route
set at 0.
The factors that most affect an HRS site score are
the proximity to a densely populated area or source of
drinking water, the quantity of hazardous substances
present, and toxicity of those hazardous substances. The
HRS methodology has been criticized for the following
reasons:
There is a strong bias toward human health effects, with
only slight chance of a site in question receiving a high
score if it represents only a threat or hazard to the en-

vironment.
Because of the human health bias, there is an even stronger
bias in favor of highly populated affected areas.
The air emission migration route must be documented by
actual release, while groundwater and surface water
routes have no such documentation requirement.
The scoring for toxicity and persistence of chemicals may be
based on site containment, which is not necessarily re-
lated to a known or potential release of toxic chemicals.
©1999 CRC Press LLC
Risk Assessment and
Waste Management
11.7
THE HAZARD RANKING SYSTEM AND
THE NATIONAL PRIORITY LIST

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